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Recover™: Scaling recycled cotton across textile products

23 Apr 2026

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MARCH 2026 | POSITION ON RECYCLED CONTENT REQUIREMENTS UNDER THE ESPR — IN RESPONSE TO THE JRC PREPARATORY STUDY (3^rd MILESTONE)

Recover™ strongly supports the introduction of mandatory recycled content information and performance requirements for textiles under the ESPR. To unlock the measure’s circularity potential, we encourage the European Commission to include recycled cotton targets beyond denim to knitted and woven products, set thresholds based on product-specific technical feasibility, continue to recognize both post-industrial and post-consumer waste streams as valid feedstock, and support the continued scaling and consolidation of mechanical recycling in Europe.

Minimum Recycled Cotton Thresholds for Textile Apparel

Recover™ is a strong advocate of the EU’s Ecodesign for Sustainable Products Regulation (ESPR) and welcomes the JRC’s proposal to introduce mandatory recycled content performance and information requirements for textiles. This is critical to create the needed market demand for recycled materials.

To maximize the measure’s impact, Recover™ emphasizes that minimum recycled cotton thresholds should extend beyond denim products. While we support the proposed 20% recycled cotton target for denim, the same opportunity should be leveraged across knitted and other woven products. Cotton, alongside polyester, is one of the most widely used fibers across textile applications. Broadening recycled cotton targets across these product categories would therefore facilitate stronger market absorption of recycled cotton volumes and provide a clear market signal for further investment in recycling capacity.

At the same time, thresholds should reflect the technical characteristics of different product categories. Denim, knitted and other woven textiles have distinct fiber and yarn specifications, meaning that recycled fiber integration levels vary across applications. Establishing product category-specific recycled cotton thresholds that account for technical feasibility would ensure targets remain realistic and implementable, while still driving textile-to-textile recycling progress.

Recover™ welcomes the recognition of post-industrial waste (PIW) alongside post-consumer waste (PCW) in recycled content obligations in the JRC’s third milestone of the Preparatory Study. PIW is a high-value, cost-competitive feedstock that enables both mechanical and chemical recycling technologies to scale, helping meet circularity targets and minimum recycled content thresholds without incentivizing waste generation. Alignment with internationally recognized traceability and verification systems, such as the Global Recycled Standard, remains essential to ensure fair competition and transparency.

A forward-looking approach to assessing recycled cotton availability will further support effective policy design. The recycled cotton market is evolving rapidly, driven by regulatory momentum, brand commitments and ongoing technological improvements in recycling technologies. Reflecting this dynamic development when assessing recycled cotton supply potential would ensure thresholds remain aligned with market growth and continue to incentivize investment in recycling capacity. Considering all relevant feedstock sources, including PIW and PCW, and application beyond apparel, such as home textiles, provides a more comprehensive view of recycled cotton flows within the textile ecosystem.

Recover™ encourages the development of Extended Product Responsibility (EPR) schemes that reward higher recycled content integration. Eco-modulation mechanisms that reduce fees for products with higher shares of recycled materials, including recycled cotton, would strengthen the business case for recycled fibers and help close the competitiveness gap with virgin materials. To ensure these incentives function effectively, eco-modulation criteria should reward recycled content regardless of geographic origin, allowing companies the flexibility needed to integrate recycled materials while recycling systems continue to scale across Member States.

Finally, clear regulatory signals are crucial to support the scaling of recycling technologies. A policy framework providing a clear pathway for closed-loop recycling, supporting the continued deployment of existing solutions while enabling technological innovation, will provide the certainty needed to drive investment across the textile recycling ecosystem.

Understanding Post Industrial Waste as essential feedstock for ESPR

Recycled cotton yarns as a structural element of ESPR

Policy Recommendations

The ESPR Delegated Act for textile apparel should:

Include recycled cotton targets for the selected product categories, within the overall recycled content performance requirement.
Set recycled cotton thresholds that reflect technical feasibility and product category-specific characteristics to ensure targets remain both realistic and implementable, while still driving meaningful progress toward textile-to-textile recycling.
Continue to recognize post-industrial waste (PIW) alongside post-consumer waste (PCW) as valid recycled content feedstock.
Adopt a foreword-looking assessment of recycled cotton availability, accounting for evolving recycling capacity, feedstock sources, and sector growth.
Provide a clear pathway for recycling technologies, supporting the continued deployment and further consolidation of mechanical recycling while enabling the scaling and development of chemical recycling technologies.
Apply eco-modulation criteria to reward the inclusion of higher recycled content, regardless of geographic origin, to stimulate investment and market uptake.

About Recover™

Recover™ is a leading European materials science company and global producer of low-impact, high-quality recycled cotton fibers and cotton fibre blends. Founded in Spain in 1914, it brings over 75 years of expertise in combining tradition with innovative technology to deliver premium, sustainable, and cost-competitive textile solutions. Its products are developed in partnership with supply chain partners, retailers, and brands to drive scalable, sustainable change in fashion, creating both environmental impact and business value. Backed by STORY3 Capital and Goldman Sachs, Recover™ is scaling its proprietary technology and, as a member of the T2T Alliance, actively supports initiatives to advance textile-to-textile recycling and industry sustainability targets.